Pennsylvania Guidance for

Applying
The ASAM Criteria, 2013
Revised August 2019

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 Contents
INTRODUCTION......................................................................................................................... 4
INTRODUCTION TO TREATMENT LEVELS OF SERVICE (The ASAM Criteria, 2013, pp. 106-107) ............. 4
ADULT LEVELS OF CARE 6-DIMENSIONAL OVERVIEW (The ASAM Criteria, 2013, pp. 175-176)............. 4
ADOLESCENT LEVELS OF CARE 6-DIMENSIONAL OVERVIEW (The ASAM Criteria, 2013, pp. 177-178).... 4
WITHDRAWAL MANAGEMENT (The ASAM Criteria, 2013, pp. 127 - 173)……………………………………………...4
1 WM (The ASAM Criteria, 2013, pp. 132-134) Ambulatory Withdrawal Management Without
Extended Onsite Monitoring ...................................................................................................... 5
2 WM: Ambulatory Withdrawal Management with Extended On-Site Monitoring (The ASAM Criteria,
2013, pp. 134 – 136) .................................................................................................................. 5
• 3.2 WM: Clinically-Managed Residential Withdrawal Management (The ASAM Criteria, 2013,
pp. 137 – 139)................................................................................................................ 5
PENNSYLVANIA LICENSED CLINICAL SUBSTANCE USE DISORDER (SUD) TREATMENT SERVICES............ 6
Early Intervention (EI) – Level .5 (The ASAM Criteria, 2013, pp. 179 - 183) ....................................... 6
Outpatient (OP) Services – Level 1 (The ASAM Criteria, 2013, pp. 184 - 196) ..................................... 6
Intensive Outpatient (IOP) Services – Level 2.1 (The ASAM Criteria, 2013, pp. 196 – 207)................... 6
Partial Hospitalization (PHP) Services – Level 2.5 (The ASAM Criteria, 2013, pp. 208 – 218) ................ 6
Opioid Treatment Services (OTS) – (The ASAM Criteria, 2013, pp. 290 – 298).................................... 6
Clinically-Managed Low-Intensity Residential Services, i.e., Halfway House (HWH) – Level 3.1 (The
ASAM Criteria, 2013, pp. 222 -234) .............................................................................................. 7
Clinically Managed Population-Specific High-Intensity Residential Services – Level 3.3 (The ASAM
Criteria, 2013, pp. 234 – 243) ...................................................................................................... 9
Clinically-Managed High Intensity Residential Services (Adult) High Intensity Rehabilitative Residential
Services – Level 3.5R (ST) and Clinically-Managed High Intensity Habilitative Residential Services 3.5H
(LT) – (The ASAM Criteria, 2013, pp. 244 – 264)............................................................................10
Clinically-Managed High Intensity Habilitative Residential Services – Level 3.5H (LT) (The ASAM
Criteria, 2013, pp. 244 – 264) .....................................................................................................11
Medically Monitored Intensive Inpatient Services – Level 3.7 (The ASAM Criteria, 2013, pp. 265 -279)
..............................................................................................................................................13
Medically Managed Intensive Inpatient Services – Level 4.0 (The ASAM Criteria, 2013, pp. 280 – 289)13
OTHER ASSESSMENT CONSIDERATIONS / SPECIAL POPULATIONS ..................................................14
Assessment Upon Re-Entry From Incarceration (The ASAM Criteria, 2013, pp. 350 – 356)....................14

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Co-Occurring Substance Use and Mental Health Disorders* ............................................................15
Parents or Prospective Parents Receiving Addiction Treatment Concurrently with Their Children or
“Pregnant Women, Women with Children” (PWWWC), (The ASAM Criteria, 2013, pp. 318 – 339) ........15
Medication Assisted Treatment (MAT).........................................................................................16
Other Populations / Considerations .............................................................................................17
TREATMENT PLANNING, CONTINUED STAY REVIEWS AND DISCHARGE PLANNING...........................18
Crosswalk of PA levels of care to The ASAM Criteria, 2013 Levels of Care..…………………...………….…………..22

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 INTRODUCTION
This document is to be utilized in applying The American Society of Addiction Medicine (ASAM) Criteria,
2013 within Pennsylvania’s Treatment System when conducting a Level of Care Assessment for initial
referral into services or for continued stay and discharge considerations after treatment engagement.
Because Pennsylvania’s robust treatment system has some nuances that are not addressed within The
ASAM Criteria, 2013, specifically related to the Halfway House and Residential levels of care, the
information contained herein will further assist in determining placement into those services. The
crosswalk of the levels of care as they have historically been referenced versus the corresponding level of
care identified in The ASAM Criteria, 2013 are also included.

This document serves to further assist the assessor by providing supplemental information for
determining the treatment needs of special populations when making a referral for services. Additionally,
guidance on treatment planning, continued stay reviews and Single County Authority (SCA) authorization
for services is included herein to provide clarification on these clinical processes as outlined in the
Pennsylvania regulations, in comparison to that which is outlined in the criteria.

The ASAM Criteria, 2013 does not supersede Pennsylvania regulations, applicable statutes, and
contractual agreements established by the Department of Drug and Alcohol Programs.

INTRODUCTION TO TREATMENT LEVELS OF SERVICE (The ASAM Criteria, 2013,

pp. 106-107)

ADULT LEVELS OF CARE 6-DIMENSIONAL OVERVIEW (The ASAM Criteria, 2013,

pp. 175-176)

ADOLESCENT LEVELS OF CARE 6-DIMENSIONAL OVERVIEW (The ASAM Criteria,

2013, pp. 177-178)

WITHDRAWAL MANAGEMENT (The ASAM Criteria, 2013, pp 127 –

173)
There are various assessment considerations for determination of withdrawal management
needs including the individual’s personal withdrawal history, course of illness, substances being
used, current withdrawal symptoms, medical and mental health complications, etc.; therefore,
assessors should be well-acquainted with the specific details outlined in The ASAM Criteria,
2013 (pp. 127 – 173), including the Dimensional Admission Criteria Decision Rules by substance,
the Risk Rating Matrix (The ASAM Criteria, 2013, pp. 73 - 104), Immediate Need and Imminent

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Danger Profile (The ASAM Criteria, 2013, p. 66), as well as the Withdrawal Management
Instruments found in the Appendix A (The ASAM Criteria, 2013, pp. 393 – 400).

1 WM (The ASAM Criteria, 2013, pp. 132-134) Ambulatory Withdrawal Management

And
2 WM: Ambulatory Withdrawal Management with Extended On-Site Monitoring (The ASAM
Criteria, 2013, pp. 134 – 136)

Ambulatory withdrawal management exists within our treatment delivery system; however,
since this activity is not indicated on the license of providers who deliver this level of care, it is
difficult to determine Pennsylvania’s current capacity for these services and individuals’ access
to these services. Work will continue to identify and expand ambulatory withdrawal
management services, as appropriate. Until then, clients should continue to use the existing
ambulatory services offered by providers. Such services may be provided by licensed SUD
providers, including outpatient providers with appropriate medical staff and services and
primary care physicians.

3.2 WM: Clinically-Managed Residential Withdrawal Management (The ASAM Criteria, 2013,
pp. 137 – 139)
Since all licensed residential withdrawal management facilities must have healthcare staff as a
regulatory requirement, there are no licensed residential treatment providers within the
Commonwealth of Pennsylvania that provide only a “social setting detoxification” that is
characterized by peer and social support. While licensed residential withdrawal management
programs may support individuals in progressing through withdrawal symptoms without any
use of medication, this is done as a service within a 3.7 WM service and not as a separate 3.2
level of care. The provision of this service as a definitive 3.2 level of care will need to be
explored as a future enhancement to the system of care.

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PENNSYLVANIA LICENSED CLINICAL SUBSTANCE USE DISORDER (SUD)
TREATMENT SERVICES
The following are The ASAM Criteria, 2013 text references for Level of Care (LOC) not
specifically addressed in this document:

Early Intervention (EI) – Level .5 (The ASAM Criteria, 2013, pp. 179 - 183) *not licensed

Outpatient (OP) Services – Level 1 (The ASAM Criteria, 2013, pp. 184 - 196)

Intensive Outpatient (IOP) Services – Level 2.1 (The ASAM Criteria, 2013, pp. 196 – 207)

Partial Hospitalization (PHP) Services – Level 2.5 (The ASAM Criteria, 2013, pp. 208 – 218)

Opioid Treatment Services (OTS) – (The ASAM Criteria, 2013, pp. 290 – 298)

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Clinically-Managed Low-Intensity Residential Services, i.e., Halfway
House (HWH) – Level 3.1 (The ASAM Criteria, 2013, pp. 222 -234)

The ASAM Criteria “do not purport to set medical or legal standard of care and may not
encompass all the levels of service options that may be available in a changing health care field
or within any particular state”, (The ASAM Criteria, 2013, p. ix). Additionally, the descriptions
are intended to provide a more comprehensive understanding of each LOC; and “are not
intended to replace or supersede the relevant statutes, licensure, or certification requirements
of any state or federal jurisdiction” (The ASAM Criteria, 2013, p. 19). Therefore, application
guidance as it pertains to Pennsylvania’s Halfway House LOC is set forth in this document and
reflects and adaptation of the criteria as it applies to the 3.1 LOC as delivered in Pennsylvania.

1. In PA, the HWH LOC is licensed as a non-hospital residential facility providing, structured,
regulated, professionally staffed services focused on developing self-sufficiency through
counseling, employment and other services. Within the criteria, the term halfway house is not
synonymous with the term halfway house as designed and delivered in Pennsylvania.

2. The ASAM Criteria’s Level 3 placements include a continuum of residential services, including
levels 3.1, 3.3, 3.5 and 3.7. Within Pennsylvania’s system of care, HWHs focus on community
reintegration including work, volunteer and educational activities most appropriately described
by The ASAM Criteria, 2013 Level 3.1, with guidance for applying the criteria to PA’s system of
care and regulatory requirements.
3. The ASAM Criteria, 2013 indicate that clinical services in this 3.1 LOC are usually provided in
an outpatient setting (The ASAM Criteria, 2013, p. 223); however, in Pennsylvania, HWH’s are
licensed, clinical providers that deliver onsite substance use disorder treatment, with referrals
to an appropriate off-site mental health provider unless a provider is also credentialed to
provide such services within the facility.

4. The HWH LOC has been and continues to be a 24-hour post stabilization service rather than
a service meant for those in the “discovery process” as described in the criteria or for those just
initiating the recovery process.
5. As always, it is essential that assessors are aware of all the service providers to which they
make referrals so that individuals are appropriately matched to the provider/facility that can
best meet the needs of the individual.

6. The ASAM Criteria, 2013 is person-centered, rather than program-focused. It is DDAP’s

expectation that individuals, in any LOC, will be treated as warranted, and if a service is needed,
the provider will ensure that the individual’s needs are met within the program’s structure or
through a referral to a specialized provider.

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7. Even though there has been legislation passed to certify or license recovery residences,
recovery houses are not authorized to provide clinical services. While housing may be an
ancillary need that can be met while an individual is participating in one of the outpatient levels
of care, the appropriate clinical service would be The ASAM Criteria, 2013 1.0, 2.1, or 2.5 LOCs,
with an ancillary referral to an approved recovery residence, but NOT an ASAM Criteria, 2013
level 3 placement. The need for housing and a safe recovery environment cannot be the sole
driver for placement into HWH/residential services, rather an individual must meet the
admission criteria of the other dimensions as well (The ASAM Criteria, 2013, pp. 228 -231).

8. DDAP is providing clarification to the Level 3.1 Adult Dimensional Admission Criteria,
Dimension 3, All Programs statement located on pages 228 – 229, The ASAM Criteria, 2013:

All Programs: The patient may not have any significant problems in this dimension. However, if
any of the Dimension 3 conditions are present, the patient must be admitted to a co-occurring
capable or co-occurring enhanced program (depending on his or her level of function, stability,
and degree of impairment). In Pennsylvania, these admission criteria can be satisfied by an
admission into a co-occurring capable, a co-occurring enhanced program, a program with a
Certificate of Approval as meeting the criteria in the co-occurring disorder competent bulletin,
or through an individual referral to a mental health provider. As noted in The ASAM Criteria,
2013, p.45: “If the emotional, behavioral or cognitive signs and symptoms are part of
addiction (e.g., mood swings because the individual is using “uppers” and “downers”), then
Dimension 3 needs may be safely addressed as part of addiction treatment.”
10. An individual is not required to have a co-occurring issue to use the 3.1 LOC, nor does
having a co-occurring condition negate placement in this LOC. Rather, the criteria are inclusive
of those individuals who may have co-occurring conditions in Level 3.1 (and all LOCs).

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Clinically Managed Population-Specific High-Intensity Residential
Services – Level 3.3 (Adult Criteria Only) (The ASAM Criteria, 2013, pp.
234 – 243)

1. Some providers may have a DDAP Non-Hospital Program license and have a Mental Health
license to address persons with severe co-occurring disorders (COD) and therefore are
equipped to serve individuals with significant cognitive dysfunction, developmental delays
and/or debilitating CODs. Currently, it is uncertain if or where such population-specific
programs exist in Pennsylvania; they are mostly unavailable. Clinicians/assessors need to be
mindful of available services and programming done by providers.
2. While there are some providers that are equipped with the level of specialty staff to serve
individuals with severe cognitive impairments or co-occurring disorders, there are no SUD
treatment programs that are licensed to serve only individuals with these specialized needs.

3. In such instances where an individual is assessed as having cognitive impairments that

require services that are adapted to fit the level of impairment and staffing requirement,
assessors and clinicians should make every effort to identify programs that can better deliver
such services, even though the facility patient population is not limited to these specialized
services or specific individuals, or concurrent referrals for specialized care should be made.
4. Where functionality is so impaired that the physical or mental health issue is primary or
supersedes the SUD need, appropriate referral to a therapeutic rehabilitation program or a
traumatic brain injury program is required, followed by SUD referral upon stabilization, as
appropriate.
5. In those instances where the 6-dimensional assessment and individual needs warrant a 3.3
LOC placement, but such services do not exist or cannot be accessed, identification of that need
should be made at the time of referral to the payor; SCAs and BH-MCOs should track the
cumulative need for this LOC. While an individual should be referred to the next available
higher level of care as indicated by The ASAM Criteria, 2013, p. 111, tracking the need for this
LOC assists Pennsylvania in assessing gaps and needed services.

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Clinically-Managed High Intensity Residential Services (Adult)
Rehabilitative Residential Services – Level 3.5R and Clinically-
Managed High Intensity Habilitative Residential Services 3.5H – (The
ASAM Criteria, 2013, pp. 244 – 264)

While neither the short or long-term LOC have been eliminated with the use of The ASAM
Criteria, 2013, references to what have historically been known as: 3B: “Medically Monitored
Short-Term (ST) Residential” and 3C: “Medically Monitored Long-Term (LT) Residential” will
now be regarded as: “Clinically-Managed High Intensity Rehabilitative Residential Services”
3.5R and “Clinically-Managed High Intensity Habilitative Residential Services” 3.5H to more
accurately reflect The ASAM Criteria, 2013 principles of person-centered treatment planning.
Because of the multiplicity of services that exist in Pennsylvania for the 3.5 LOC, an adaptation
has been made to appropriately reflect the delivery of services. (The terms high and highest as
published in the 2018 version of this document were changed to rehabilitative and habilitative in
response to feedback from the field).

Clinically-Managed High Intensity Residential Services (Adult) High Intensity

Rehabilitative Residential Services – Level 3.5R (The ASAM Criteria, 2013, pp.
244 – 264)
1. While the distinction in delivery of services between these two types of 3.5 service exists, it
is not delineated within the PA licensing regulations. Both types of care are licensed under the
Chapters 709 & 711 Standards for Licensure of Freestanding Treatment Facilities. Furthermore,
although programs licensed under the 709 & 711 regulations may have medical staff or access
to medical staff, since the licensing regulations do not specify the requirement for medical
professionals to be employed within these LOCs, both LOCs are best defined as “Clinically
Managed” Residential Services as opposed to the previously defined “medically monitored”.

2. When an individual meets the admission criteria for the 3.5 LOC, the additional placement
considerations that follow specifically for Pennsylvania should be made in determining the
distinction between “Clinically-Managed High Intensity Rehabilitative Residential Services”
(Short-Term) and “Clinically-Managed High Intensity Habilitative Residential Services” (Long-
term) LOCs.
3. To be designated as a 3.5 Co-Occurring Enhanced provider (3.5E), such a designation must be
assigned to a provider by virtue of being licensed as a mental health Residential Treatment
Facility for Adults (RTF-A), in addition to their drug and alcohol license. Such designations have
been verified and issued through the Departments of Human Services (DHS) and Drug and
Alcohol Programs (DDAP).

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4. For Clinically-Managed High-Intensity Rehabilitative Residential Services (3.5R) to be
appropriate, the individual must need rehabilitation services, rather than habilitation services
(see The ASAM Criteria, 2013, pp. 419 & 427 for definitions of habilitation and rehabilitation).
Many persons start stabilization/treatment in High-Intensity Rehabilitative services, but after
careful monitoring and further comprehensive assessment, transition to High-Intensity
Habilitative services may be necessary.

Clinically-Managed High Intensity Habilitative Residential Services – Level 3.5H

(The ASAM Criteria, 2013, pp. 244 – 264)

1. For Clinically-Managed High-Intensity Habilitative Residential Services (3.5H) to be

appropriate, the individual must need habilitation services, rather than rehabilitation services.
(see The ASAM Criteria, 2013, pp. 419 & 427 for definitions of habilitation and rehabilitation).
“Habilitation” as referenced and delivered within an adult SUD treatment program primarily
addresses those life-skill issues identified in dimension three below and not instruction or
interventions related to daily living skills such as bathing, toileting, dressing, etc.

2. While placement in the most appropriate LOC should be determined by clinical assessment
and judgment, there may be court-ordered appointments to the Clinically Managed High-
Intensity Habilitative Residential LOC or designated specialized “Criminal Justice”
placement/residential service. Please refer to the text to more fully understand how to
approach and document mandated treatment episodes. (The ASAM Criteria, 2013, p. 20).

3. For either LOC, Clinically Managed High-Intensity Rehabilitative or Habilitative Residential

Services, when an individual has both SUD and Mental Health conditions and where there are
co-occurring capable, or co-occurring enhanced services available, such would be the more
appropriate type of service/referral. See “Co-Occurring SUD and MH Disorders,” p. 16 of this
document.

4. Additionally, for either LOC, the length of service in treatment should be variable, and based
on the continued assessment of the individual’s symptom severity and level of functioning.

5. When determining placement in a Women’s with Children Program as 3.5H (see The ASAM
Criteria, 2013, pp. 318 – 339). Specific considerations should be evaluated as delineated on
pages 15 - 17 of this guidance document.

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The distinguishing factors between 3.5R and 3.5H apply when an individual meets criterion
for 3.5R, but ALSO demonstrates the following specifications:

• DIM 3: The individual must meet at least 2 of the following:

a) Disordered Living Skills, i.e., lacking socially acceptable norms/coping skills; history of
inability to internalize social responsibility; history of significant, consistent
substance use before early adolescence.
b) Disordered Social Adaptiveness, i.e., history of repetitive antisocial or criminal
behavior with or without incarceration; history of rebellion/denigration of
acceptable societal values with disregard of authority and basic rules.
c) Disordered Self-Adaptiveness, i.e., persecutory fear, poor sense of self-worth, self-
hatred; history of chronic external focus/seeking of external stimuli to the exclusion
of developing internal supports; inability to develop supportive relationships;
blaming others and difficulty/unwillingness to make decisions to effect positive
changes in the circumstances that the individual regards as undesirable.
d) Disordered Psychological Status: i.e., history of early onset (pre-adolescence) of
emotional blunting or impairment, or developmental disorders as exemplified by:
lack of geographical roots, lack of healthy role-modeling opportunities, little or no
opportunity for parental bonding or guidance, a pervasive history of parental
enabling, gang membership, dysfunction parental modeling (such as long-term
criminal behavior or other antisocial lifestyles) OR a history of significant impulsivity
without due regard for potential negative consequences.
• DIM 4: The individual has little to no recognition that his or her SUD use is a problem or
is causing a problem; requires 24-hr, directed motivational interventions to gain insight
into the SUD to make behavioral changes.
• DIM 5: Must meet one of the following: 1) The individual demonstrates a lifetime
history of repeated incarceration with a pattern of relapse to substances and
uninterrupted use outside of incarceration, with imminent risk of relapse to addiction or
mental health problems and recidivism to criminal behavior. Imminent danger of
relapse is accompanied by an uninterrupted cycle of relapse-reoffending-incarceration-
release-relapse without the opportunity for treatment, 2) Individual is assessed to be
in danger of substance use with attendant severe consequences, and is in need of 24-
hour professionally directed clinical interventions and support, or 3) individual has
attempted to reduce or control substance use, but has been unable to do so in his/her
immediate environment.
• DIM 6: Must meet one of the following: 1) Individual lives in an environment which
undermine his/her efforts to change or in which treatment is unlikely to succeed or 2)
There is danger of physical, sexual, and/or severe emotional victimization in the
individual’s current environment.

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Medically Monitored Intensive Inpatient Services – Level 3.7 (The ASAM Criteria,
2013, pp. 265 -279)

1. Because of the medical staffing requirement of this LOC, Medically Monitored Residential
Providers licensed under the 710 or 711 regulations will most likely qualify to deliver 3.7
services, i.e., residential treatment provided in a healthcare facility, a hospital capable of
monitoring; a psychiatric hospital.
2. However, in such instances where a program licensed under the 709 regulations has the
required medical staffing (most likely those that also provide withdrawal management services)
and has been designated as a 3.7 by the process established by DDAP/DHS it would also meet
the requirements to provide Medically Monitored Intensive Inpatient Services.
3. Designations for 3.7 may be for physical health (PH) or mental health (MH). To be
designated as a 3.7 PH provider, physician access and nursing care must be available around the
clock. To be designated as a 3.7 MH provider, Mental Health Professionals must be on staff
around the clock in addition to medical staff and a provider must have dual licensure in SUD
and mental health (inpatient or RTF-A). Such designations have been verified and issued
through the Departments of Human Services (DHS) and Drug and Alcohol Programs (DDAP).

Medically Managed Intensive Inpatient Services – Level 4.0 (The ASAM Criteria,
2013, pp. 280 – 289)

Designations for 4.0 may be for physical health (PH) or mental health (MH). To be designated
as a 4.0 PH provider, physician access and nursing care must be available around the clock
within a healthcare facility. To be designated as a 4.0 MH provider, the provider must have a
mental health inpatient license in addition to a drug and alcohol license. Such designations
have been verified and issued through the Departments of Human Services (DHS) and Drug and
Alcohol Programs (DDAP).

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OTHER ASSESSMENT CONSIDERATIONS / SPECIAL POPULATIONS
Assessment Upon Re-Entry From Incarceration (The ASAM Criteria, 2013, pp.
350 – 356)
1. Forced abstinence resulting from a period of incarceration does not equate to recovery and
therefore an individual’s SUD condition should be assessed based upon the 6 months prior to
incarceration as well as in light of any clinical services received while incarceration, along with
present motivation and current stage of change. While incarceration should never be a
substitution for needed treatment, assessors must do a clinical assessment based on ALL 6
dimensions.
a) While Dimension 1, Acute Intoxication and Withdrawal Potential may be low, accurate
clinical assessment of the remaining Dimensions will be especially important.
b) In assessing all dimensions, clinical attention should be in Dimension 4: “Readiness to
Change”, as is indicated in the criteria, the “…assessment of state of change is
designated from the clinician’s point of view on what the individual needs to change and
accept as a condition requiring treatment.”
c) In assessing Dimension 5, “Relapse, Continued Use, or Continued Problem Potential”:
The clinician should “assess the need for relapse prevention services. If the person has
not achieved a period of recovery from which to relapse (see definition of relapse and
expanded constructs (The ASAM Criteria, 2013, p. 52), this dimension assesses the
potential for continued use for SUD, or continue problem potential…” If an individual
was untreated or undertreated during incarceration, it is clinically unlikely that forced
abstinence resulted in recovery. The ASAM Criteria, 2013 glossary defines abstinence
and recovery as follows:
• Abstinence is “intentional and consistent restraint from the pathological pursuit
of reward and/or relief that involves the use of substances and other behaviors.”
(The ASAM Criteria, 2013, p. 411)
• Recovery is “a process of sustained action that addresses the biological,
psychological, social, and spiritual disturbances inherent in addiction. This effort
is in the direction of a consistent pursuit of abstinence, addressing impairment in
behavioral control, dealing with cravings, recognizing one’s behaviors and
interpersonal relationships, and dealing more effectively with emotional
responses. Recovery actions lead to reversal of negative, self-defeating internal
processes and behaviors, allowing healing of relationships with self and others.
The concepts of humility, acceptance, and surrender are useful in this process.”
(The ASAM Criteria, 2013, p. 427)
2. While it is not specifically noted in the criteria, it is implied by the information cited above,
that assessors will adhere to the premise that jail time should not replace the need for clinical
or support services. Rather, clinical judgment must be utilized about substance use and
difficulties experienced prior to incarceration (individual history) with consideration given to

14
clinical interventions that may or may not have been received while incarcerated and how this
impacts the assessment of risk.

3. Otherwise, The ASAM Criteria, 2013 (pp. 350 – 356) includes consideration for SUD treatment
for those who are currently incarcerated which can be utilized by assessors in the settings
described.

Co-Occurring Substance Use and Mental Health Disorders

1. There is no LOC in PA that will be restricted to only individuals who have a co-occurring
condition; however, there may be providers that specifically serve only those with a co-
occurring condition. Such programs would likely be dually licensed.

2. DDAP has historically required the assessment of co-occurring needs and appropriate referral
by the SUD assessor, and follow up by the case manager. Whenever possible, individuals were
to have been referred to integrated services. The transition to The ASAM Criteria brings this
assessment and referral requirement to the forefront. While it may be the case that individuals
who have a SUD may not have a mental health (MH) condition, and individuals who have a MH
condition may not have a SUD, co-morbidity often exists and when it does, it is important that
they are treated concurrently.

3. DDAP and OMHSAS recognizes that the availability of integrated services is frequently a gap
in our service-delivery system and that prior efforts in strengthening co-occurring integrated
care will need to be resurrected to improve services overall. Until this occurs, co-occurring
disorders must be considered as part of the assessment process and referrals made
accordingly: when available to a provider able to offer integrated services, to a provider that
can offer co-occurring capable or co-occurring enhanced services, or to a separate behavioral
health provider as individual need and available services dictates.

4. While the criteria’s primary focus in DIM 3 is to assess the need for mental health services,
The ASAM Criteria, 2013 recognizes that thought disorders, anxiety, guilt and/or depression
may be related to SUD problems, that are currently stable but may lead to relapse if not in a
structured environment. “If the emotional, behavioral or cognitive signs and symptoms are
part of addiction (e.g., mood swings because the individual is using “uppers” and “downers”),
then Dimension 3 needs may be safely addressed as part of addiction treatment.” (The ASAM
Criteria, 2013, p. 45)

Parents or Prospective Parents Receiving Addiction Treatment Concurrently

with Their Children or “Pregnant Women, Women with Children” (PWWWC),
(The ASAM Criteria, 2013, pp. 318 – 339)
1. As per PA Act 65 of 1993 and by way of federal substance abuse block grant (SABG)
requirements, Pennsylvania has a robust system of services for pregnant women and women
with children, including specialized providers offering care to these individuals. While The ASAM
Criteria, 2013 broadens the scope to include the parenting individual, Pennsylvania has few, if
15
any, programs that admit parenting men with their children. Nevertheless, regardless of
gender, the needs of the parenting individual with a SUD should be considered at the time of
assessment and recommendations/referral for treatment and appropriate supports for the
individual and child should be considered, referrals made, and appropriate follow up conducted
for any LOC.

2. When assessing women and women with children particular placement, considerations
should be taken into account including:
a) Parenting – as noted above. For those women in need of residential services, care
should be made in referring to a program than can provide appropriate support and
services for her children, including those programs that can accommodate women with
their children, as well as address parenting issues.
b) Trauma – The prevalence of trauma is very high in this population; therefore, referral
should be made with consideration of this history and where trauma-informed care can
be received.
c) Medical – in addition to co-occurring issues that should be assessed as determined by
the criteria, physical/health conditions, especially relevant to women, should be
assessed and addressed, including by not limited to: sexually transmitted infection,
obstetrical and gynecological issues (high-risk and un-intended pregnancy, abortion,
rape, etc.), eating disorders, etc.

3. Many of the considerations regarding parenting or pregnant women noted above, are
discussed in the Admission Criteria for Parenting or Pregnant Women (The ASAM Criteria, 2013,
pp. 318 – 339) and in such instances, the clinician should refer to these specialized services.
(Note: pregnant women and individuals who use intravenous drugs/women remain a priority
population to receive services as determined by the federal SABG).

4. Additionally, it is recommended that individuals receive training in those issues that are
unique to women to better assess and treat this population. SAMHSA’s Tip 51: “Addressing the
Specific Needs of Women” (https://store.samhsa.gov/product/TIP-51-Substance-Abuse-
Treatment-Addressing-the-Specific-Needs-of-Women/SMA15-4426) is a helpful resource in
making placement determinations and for guiding treatment services.

Medication Assisted Treatment (MAT)

1. Historically, while Pennsylvania has had licensed Narcotic Treatment Programs (NTPs, also
known as Opioid Treatment Programs/OTPs), this was delivered primarily as a separate service
and not embedded within the full continuum of care. In keeping with the true intent of
medication as an assistance to treatment, The ASAM Criteria, 2013 recognizes the use of
medications in all levels of care across the continuum, even if the treatment provider is not the
prescriber of the medication. This ensures/encourages the coordination of care between
therapeutic and pharmaceutical interventions.

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2. For referral to an NTP using methadone, per federal regulations (with certain exceptions), an
individual must be 18+ years of age and be opioid dependent for over one year.

3. The criteria are guided by an individualized, person-centered approach to services rather

than a program-driven, fixed length-of-stay model. It is DDAP’s expectation that individuals will
be treated according to their needs, and if medication is warranted, that the provider will
ensure that the individuals’ needs are met. It is imperative that providers licensed as “drug-free
providers” understand the expectation that medications that are being used to address an
individual’s SUD be regarded similarly to other medication (insulin, beta blockers, etc.) that are
not prescribed by them and do not preclude the admission of individuals on MAT into services.

4. Clinicians and programs are encouraged to reference SAMHSA’s TIP 63, “Medications for
Opioid Use Disorder” (https://store.samhsa.gov/product/TIP-63-Medications-for-Opioid-Use-
Disorder-Full-Document-Including-Executive-Summary-and-Parts-1-5-/SMA19-5063FULLDOC)
as well as “The ASAM National Practice Guideline For the Use of Medication in the Treatment
of Addiction Involving Opioid Use”( https://www.asam.org/docs/default-source/practice-
support/guidelines-and-consensus-docs/asam-national-practice-guideline-supplement.pdf).

Other Populations/Considerations
1. It is of utmost importance that assessors and clinicians be appropriately trained in and aware
of issues that may present with specific populations. This is true of those populations
addressed above, as well as, but not limited to others such as veterans, LGBTQ individuals,
adolescents, Hispanic/Latino or other cultural and language diversities that may present in the
assessment or clinical setting. Such considerations may impact referrals, i.e., the most
appropriate setting in which to receive care, how services should be delivered, etc.

2. In instances where there is a multiplicity of identified needs, assessors should be mindful of

the need for case management services and/or recovery support services. While these may not
directly impact the application of The ASAM Criteria, 2013 such services may enhance the
treatment and recovery process and facilitate the clinical experience.

3. Trauma has been experienced by many people and therefore should be a consideration in
the assessment and treatment process through a trauma-informed approach.

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Guidance for Treatment Planning, Continued Stay Reviews and
Discharge Planning
Intake and level of care determination is based on a comprehensive assessment of the
individual to be served. It is from this initial “Level of Care Assessment” that a recommendation
for treatment is made. In Pennsylvania, there have been several different strategies utilized
across counties for conducting this initial assessment. Sometimes the assessment is conducted
by a case management unit; elsewhere, it is completed by an independent assessment center
or treating clinician within a licensed treatment facility. In all cases, once admitted to services,
a therapist will build upon the initial information obtained in the Level of Care Assessment to
complete a full, bio-psychosocial evaluation, upon which the treatment plan/service plan is
established.

Therapeutic interventions, including counseling sessions, are based upon the treatment plan
goals and objectives, which are reviewed during each counseling session and adjusted
according to the individual’s progress and/or emerging treatment needs. The treatment
planning process is fluid (i.e., goals and objectives are completed, adjusted, and/or added),
based upon the individual’s progress or lack thereof and upon ongoing 6-dimensional
assessment utilizing The ASAM Criteria, 2013. This ongoing process is consistent with the
direction provided in the text on pages 105 -112 on Service Planning and Placement and on
pages 299-306 on Continued Stay/Discharge criteria. Progress and changes to the treatment
plan should be noted accordingly.
While the treatment plan should be consistently utilized and evaluated to determine ongoing
appropriateness/need for services, PA regulation establishes minimum standards for formalized
treatment plan updates. These regulatory minimums for treatment plan reviews remain intact,
although treatment plan updates can occur more frequently than the regulations require to
accurately reflect the individual’s progress.

Because of the need for clinical judgement and individualized care, DDAP is purposefully NOT
articulating specific timeframes for treatment plans, continued service reviews or authorization
protocols. Instead, this guidance is provided in support of the principles articulated in The
ASAM Criteria, 2013 and in anticipation of treatment plans being written in an individualized,
person-centered, stage specific way. It is also expected that continued service in treatment will
be clearly justified in the medical record and reflective of treatment that matches the
individual’s level of functioning while meeting their needs in an effective and timely manner,
regardless of the authorization process.

The following items provide further guidance on Treatment Plans/ Updates:

1. Establishing a treatment plan should be in direct correlation with the needs
identified by the individual being served, his or her stage of change, and be reflective
of the 6-dimensional assessment utilizing The ASAM Criteria, 2013. Treatment plan

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 goals should be individualized and determined in collaboration with the person in
treatment. Additionally, it is expected that goals will be developed in a manner that
would assist the individual in taking measurable, specific, progressive steps through
a change process.
2. Individuals should have a copy of their treatment plan and it should be
referenced/reviewed as a part of the individual counseling session/therapeutic
process.
3. Clinical evaluation and monitoring should be an ongoing part of the therapeutic
process from admission/level of care determination through discharge and should
encompass the 6 dimensions of the criteria.
4. As indicated in The ASAM Criteria, 2013, page 110, progress in all the dimensions
should be assessed at regular intervals to ensure comprehensive and appropriate
treatment. This may or may not be done as a formal update as indicated by
regulation, depending upon the individual’s presenting circumstances.
5. Progress and case consultation notes should reflect the current treatment plan and
circumstances impacting the completion or non-completion of the individual’s
treatment goals and any newly identified needs – including crises.
6. Changes to the content of the treatment agenda for each individual should, at a
minimum, be noted within progress notes or case consultation notes within an
individual’s chart. The significance of the issue should be a determining factor in
making a formal update to the treatment plan.
7. When such needs and issues warrant a revision to the goals or objectives of the
treatment plan, the clinician should indicate this immediately, since treatment plans
are to be a fluid process to address individual needs. Formal treatment plan updates
conducted with the treatment team and/or medical director may not exceed the
time established by regulation specific to each type of service.
8. The requirements for conducting a formal treatment plan update are outlined in the
Pennsylvania Regulations, Chapters 709.52(b), 709.82(b), 709.92(b), 709.123 (b)(2),
710.42(c), 711.52(d), 711.82(d), 711.92(d) 715.23 (d)(2), and 715.24(5)(iii). These
are minimum standards for conducting an update.
While Narcotic Treatment Standards for outpatient (not withdrawal management)
indicate that treatment plans must be reviewed and updated as required by
standards established by Chapters 709,710 and 711, an outpatient NTP may request
an exception to the timeframe for stable individuals who receive direct counseling
less than twice per month (see Licensing Alert 01-14).
9. DDAP strongly recommends that providers establish and publish/maintain on file
policy and procedure for the frequency of treatment plan updates reflective of The
ASAM Criteria, 2013 and in accordance with Pennsylvania regulation as noted above.

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The following provides guidance relative to formalized Continued Stay Reviews:
1. Whether or not an individual remains appropriate for the current level of care should be
determined by the ongoing, clinical assessment process noted above and whether the needs
identified in the treatment plan have adequately been accomplished or can continue to be
addressed at that intensity of service. Clinicians are directed to follow the guidance
indicated in The ASAM Criteria, 2013, pages 299 – 306.
2. While the treatment planning and progress noted should be the “road map” for the
therapeutic process and in determining continued stay, transfer or discharge, Pennsylvania
regulations do not indicate a timeline for conducting official continued stay
reviews.
3. Such formal reviews as would be especially necessary for payors (SCAs, BH-MCOs, third
party payors) should be dictated by clinical/medical necessity as determined by clinical
assessment utilizing all 6-dimensions of the ASAM Criteria. Formal reviews should be
at intervals that provide appropriate time frames to a) support meeting the needs of
the individual; b) do not create an administrative burden for the clinician substantiating the
need for ongoing service; and c) provide the payor with timely enough information to
responsibly manage resources. (see section below on “Authorization for Payment”)

The following provides guidance relative to Authorization for Payment by the

SCA:

“Clinicians who make placement decisions are expected to amplify the criteria with their clinical
judgement, their knowledge of the patient, and their knowledge of the available resources. The
ASAM Criteria, 2013 is not intended as a reimbursement guideline, but rather as a clinical
guideline for making the most appropriate treatment and placement recommendation for an
individual patient with a specific set of signs, symptoms, and behaviors.” (The ASAM Criteria,
2013, p. 17). However, the following guidelines are suggested to assist with the practical
utilization of continued stay determinations related to authorizations by payors, especially
SCAs.

1. DDAP understands that treatment planning and continued stay reviews should be based on
the individual’s progress in treatment or lack thereof and that while this is true,
authorization for payment of services using public funds has often been tied to this process.

2. In order that the authorization for payment process not be cumbersome for the provider or
payor and to allow for proper fiscal management for payors, DDAP is recommending that
such authorizations be issued according to the following maximum time frames as listed
below:

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 Level of Care Maximum Timeframe for Authorization
Outpatient (1.0) 6 months
IOP (2.0) 10 weeks
Partial Hospitalization (2.5) 10 weeks
Residential Treatment/Inpatient Non-hospital 3.5 R, 3.7: 14 days initial, and every 7 days
(3.1, 3.5, 3.7) thereafter
3.1 (HWH), 3.5 H: up to 30 days initial, 30 days
secondary, and every 15 days thereafter
Non-hospital Residential WM (3.7 WM) Up to 5 days initial, and daily thereafter
Inpatient WM (4.0)
NTP OP OP- 6 months for bundled authorization
OP-IOP-Fee-for-service/unbundled 6 mos. OP, 10
weeks IOP, 10 weeks PHP

2. It remains the provider’s responsibility to notify the payor in a timely fashion if the clinical
treatment plan update or clinical continued stay review as previously outlined in this
document necessitates an extension or reduction/discontinuation of authorized payment
time for service or a change in level of care.

3. For SCA payors: Continued stay/utilization review to substantiate authorization for

payment of services may be completed by a case manager when the review is restricted to
a clinical decision made by the case manager and where fund-management and the actual
authorization of funds being issued is being managed by a separate person, such as a fiscal
officer or SCA Administrator. If the function of utilization review is conducted by the same
SCA staff doing fund-management, the restrictions of 4 Pa. Code §255.5 apply and content
of the review is restricted to the 5 elements permissible by the regulation.

21
 ASAM Crosswalk with PA’s System of Care - August 2019
LOC ASAM Adult ASAM LOC Name ASAM Program Description Summary for Adults ASAM PA Service Equivalent Licensed PCPC
Criteria Adol LOC Adult Program/
Services Regulation
1 WM Ambulatory Withdrawal Outpatient WM: without extended on-site monitoring p. 128 OBOTs; OTP/NTP - See 715; 709 N/A
Withdrawal Management (WM) Application Guidance
WITHDRAWAL MANAGEMENT

Management Document
p. 132i
2 WM p. 134 Ambulatory WM Outpatient WM: with extended on-site monitoring p. 128 OBOTs; OTP/NTP - See 715, 709 N/A
Application Guidance
Document
3.2 WM Clinically Managed Clinically Managed “Social setting program”; Managed by p. 128 See Application 709 N/A
p. 137 Residential WM clinicians; NOT medical staff Guidance Document

3.7 WM Medically Monitored “Freestanding WM center”; 24-hour observation and availability of p. 128 Non-hospital residential 709; 711 3A
p. 139 Inpatient WM medical staff detoxification
4 WM p. 141 Medically Managed Intensive Acute care or psychiatric hospital unit; Availability of specialized p. 128 Hospital-based 710 4A
Inpatient WM medical consultation; full medical acute care; ICU as needed detoxification
0.5 p. 179 Early Intervention An intervention program for individuals who do not meet .5 Early intervention N/A .5
diagnostic criteria of a SUD
1 p. 184 Outpatient Services <9 hours regularly scheduled sessions per week 1 OP 709; 711 1A
2.1 p. 196 IOP Services 9 to 19 hours of structured programming per week 2.1 Intensive OP 709; 711 1B
2.5 p. 208 PHP Services 20+ hours of clinically intensive programming per week 2.5 Partial hospitalization 709; 711 2A
programs
3.1 p. 222 Clinically Managed Low- Halfway house, group home or other supportive living environment 3.1 Halfway house (see 709 2B
intensity Residential w/24-hour staff and integration with clinical services Application Guidance Doc)
3.3 p. 234 Clinically Managed, Therapeutic rehab or TBI program; combination of low-intensity -- See Application -- --
Population-specific, High- rehab services to meet (primarily cognitive) functional limitations so Guidance Document
intensity Residential great to prohibit participation in OP or other LOCs
LEVELS OF CARE

3.5 p. 244 Clinically Managed, High- 24-hour supportive treatment environment 3.5 Non-hospital residential 709; 711 3B;
intensity Residential Services Tx or Tx offered in 3C
criminal justice-related
(See Application
Guidance Document)
3.7 p. 265 Medically Monitored Inpatient treatment within an acute hospital, psych center, or 3.7 Res Tx provided in a 709ii; 710; 3B
Intensive Inpatient Services freestanding residential facility; designed to meet functional healthcare facility or 711
limitations in Dim 1, 2, 3 (w/d, asthma, diabetes, etc., i.e. admission hospital capable of
based on co-morbidity of medical or psych); physician monitoring; medical monitoring, or
nursing care; additional medical specialty; psych services; clinical psych hospital with D&A
staff & daily clinical services; co-occurring enhanced program license, or free-standing
psych hospitals
4 p. 280 Medically Managed Intensive Services delivered in an acute care inpatient setting; for patients 4 Hospital-based 710 4B
Inpatient Services whose biomedical, emotional, behavioral, cognitive problems are residential inpatient
so severe that they require primary medical and nursing care
Opioid OTS (Opioid Treatment Agonist and antagonist meds in OTP and OBOT setting -- NTPs; OBOTs-See ALL LOCs --
Treatment Services) Application Guidance
Services Document
(OTS) p. 290
i
ii
Page numbers are found in the American Society of Addiction Medicine (2013). The ASAM Criteria: Treatment Criteria for Addictive, Substance-Related, and Co-Occurring Conditions. Carson City, NV: The Change Companies®.
In some instances where appropriate medical staffing exists (as per Licensing Alert 3-02), these services may be provided by a program licensed as a 709.